CIBC Investor Presentation
Canadian Bail-in Regime - Comparison to Other Jurisdictions
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Bail-in implementation in other jurisdictions has increased the riskiness of bail-inable bonds vs. non-bail-inable bonds:
Legislative changes prohibit bail-outs, increasing the probability that bail-in will be relied on
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The hierarchy of claims places bail-in debt below deposits and senior debt through structural subordination, legislation or contractual means
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Bail-in is expected to rely on write-down of securities, imposing certain losses on investors
The Canadian framework differs from other jurisdictions on several points:
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The Canadian government has not introduced legislation preventing bail-outs
Canadian senior term debt will be issued in a single class and will not be subordinated to another class of senior term debt like other jurisdictions such as
the US and Europe
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Canada does not have a depositor preference regime; bail-in debt does not rank lower than other liabilities
No Creditor Worse Off principle provides that no creditor shall incur greater losses than under insolvency proceedings
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There are no write-down provisions in the framework
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Conversion formula under many scenarios may result in investor gains
1 As referenced in the Bank Recapitalization (Bail-in) Regulations: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-57/FullText.html
2 Decreased to 22.50% on March 13, 2020 upon decrease of Domestic Stability Buffer to 1.00% (buffer will not increase for at least 18 months)
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